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2 hours ago, Purplemandinga said:

But would Company A being entirely inside of a ESOP prevent a controlled group from forming with a company that it owns 100% of? I want to think this is still a Parent Subsidiary controlled group of A & B.

If a corporation (A here) owns 100% of another corporation (B here) they are in one controlled group. Doesn't matter than an ESOP owns A. 

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